Isidro Avalos Vanegas v. Triple S. Pallets, LLC

CourtCourt of Appeals of Virginia
DecidedOctober 29, 2024
Docket1900232
StatusUnpublished

This text of Isidro Avalos Vanegas v. Triple S. Pallets, LLC (Isidro Avalos Vanegas v. Triple S. Pallets, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Isidro Avalos Vanegas v. Triple S. Pallets, LLC, (Va. Ct. App. 2024).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, Malveaux and Raphael UNPUBLISHED

ISIDRO AVALOS VANEGAS MEMORANDUM OPINION* v. Record No. 1900-23-2 PER CURIAM OCTOBER 29, 2024 TRIPLE S. PALLETS, LLC, ET AL.

FROM THE VIRGINIA WORKERS’ COMPENSATION COMMISSION

(Adam J. Dourafei; Lauren Carroll; Commonwealth Law Group, on brief), for appellant.

(Christopher M. Kite; Lucas & Kite, PLC, on brief), for appellees.

The Virginia Workers’ Compensation Act prohibits the award of benefits for a work-

related injury “caused by . . . [t]he employee’s willful breach of any reasonable rule or regulation

adopted by the employer and brought, prior to the accident, to the knowledge of the employee.”

Code § 65.2-306(A)(5). The Workers’ Compensation Commission denied benefits to Isidro

Vanegas under that provision. The Commission found that his injury was caused by his willful

failure to replace a safety guard on the saw he was operating, resulting in lacerations to his hand

and finger. Vanegas claims that the Commission misapplied the law and that the evidence, in

any case, failed to prove a willful violation of any safety rule. Finding the appeal “wholly

without merit,” Code § 17.1-403(ii)(a); Rule 5A:27(a), we dispense with oral argument and

affirm the Commission’s decision.

* This opinion is not designated for publication. See Code § 17.1-413(A). BACKGROUND

We review the evidence in the light most favorable to the employer, the prevailing party

before the Commission. Davis v. Wal-Mart Assocs., 80 Va. App. 526, 530 (2024). Vanegas

injured his right hand and middle finger while using a wood-cutting machine. The machine

operates by feeding pieces of wood through a saw. The saw has a safety guard, which workers

sometimes raise to clean the saw blade. Vanegas knew of the employer’s safety rule requiring

workers to replace the safety guard over the saw blade before operating it. Vanegas said that he

had not received formal training on using the machine and had not reviewed any training or

safety manual. But he acknowledged that his supervisor showed him how to use the machine.

Vanegas learned how to perform cleaning and maintenance, including lowering the safety guard

and putting it back in place before activating the saw blade.

One day, Vanegas turned off the machine and lifted the safety guard to adjust and clean

the saw blade. But he failed to replace the safety guard. Vanegas and another employee

resumed using the machine without the guard in place. While walking by the spinning blade,

Vanegas accidentally touched it, causing a deep laceration to his right hand and middle finger.

After receiving medical treatment and undergoing surgery, Vanegas was temporarily

unable to work. He filed a claim seeking temporary-total-disability benefits, a medical award,

and reimbursements. The employer responded that Vanegas’s claims were barred by Code

§ 65.2-306 because he was injured through his own willful misconduct by failing to replace the

safety guard on the saw.

At an evidentiary hearing before the deputy commissioner, Vanegas testified that he

“forgot” to replace the guard after cleaning the blade. The deputy commissioner denied

Vanegas’s claim for benefits, finding that Vanegas’s injury resulted from willful misconduct.

Vanegas appealed to the full Commission.

-2- The full Commission affirmed. It concluded that Vanegas “knew that he was forbidden

to operate the saw without the guard in place, yet he intentionally undertook the forbidden act.”

Citing Layne v. Crist Electrical Contractor, Inc., 64 Va. App. 342 (2015), the Commission held

that Vanegas’s conduct qualified as willful failure under Code § 65.2-306.1

Vanegas noted a timely appeal to this Court.

ANALYSIS

Vanegas argues that the Commission misapplied the law by finding that willful

misconduct can arise from negligent acts that were unintentional. He also argues that even if the

Commission correctly applied the law, there was insufficient evidence to support a finding of

willful misconduct.

We review the Commission’s determinations of law de novo. Davis, 80 Va. App. at 534.

But the Commission’s factual findings are “conclusive and binding,” Code § 65.2-706(A), as

long as “‘there was credible evidence presented such that a reasonable mind could conclude that

the fact in issue was proved,’ even if there is evidence in the record that would support a contrary

finding.” Anderson v. Anderson, 65 Va. App. 354, 361 (2015) (quoting Artis v. Ottenberg’s

Bakers, Inc., 45 Va. App. 72, 84 (2005) (en banc)). Whether a claimant committed a willful

violation under Code § 65.2-306(A)(5) is an issue of fact. Layne, 64 Va. App. at 350 (quoting

Mills v. Va. Elec. & Power Co., 197 Va. 547, 551 (1955)).

Code § 65.2-306(A)(5) prohibits an employee from obtaining compensation benefits if

the employee commits a “willful breach of any reasonable rule . . . adopted by the employer and

1 Commissioner Marshall dissented, insisting that a “violat[ion] of a known rule by forgetting to perform an act” is not an intentional act that constitutes willful misconduct. He viewed the evidence as showing that Vanegas simply forgot to replace the safety guard, and his operation of the saw without the guard was “accidental and at most negligent.” He saw “no evidence that [Vanegas] operated the saw with knowledge that the guard was not on.” -3- brought, prior to the accident, to the knowledge of the employee.” An employer must show four

things to prevail on a willful-violation defense under Code § 65.2-306(A)(5):

• the employer’s safety rule was reasonable;

• the rule was known to the employee;

• the rule was promulgated for the benefit of the employee;

• the employee intentionally undertook the forbidden act.

Layne, 64 Va. App. at 349-50 (quoting Owens Brockway v. Easter, 20 Va. App. 268, 271

(1995)). The only disputed issue here is whether Vanegas “intentionally undertook the forbidden

act.”

An employer may establish a willful violation without “proving that the employee, with

the rule in mind, purposefully determined to break it. It is sufficient to show that, knowing the

safety rule, the employee intentionally performed the forbidden act.” Spruill v. C.W. Wright

Constr. Co., 8 Va. App. 330, 334 (1989) (quoting Riverside & Dan River Cotton Mills, Inc. v.

Thaxton, 161 Va. 863, 871-72 (1934)); see Thaxton, 161 Va. at 872 (“If the employee knows the

rule, and yet intentionally does the forbidden thing, he has ‘wil[l]fully failed to obey’ the rule.”).

We applied this principle in Layne to find that the claimant “intentionally performed the

forbidden act” proscribed by a warehouse’s “‘lockout-tagout’ rule.” Layne, 64 Va. App. at 355-

56. That rule required warehouse employees to shut down a bridge crane and electrified rails

before working near the crane. Id. at 346. The claimant was not given any written materials

about the rule, nor did he attend the employer’s formal safety orientation. Id. But he knew about

the rule after receiving a tour of the facility, and other employees told him that the rule was

important. Id. at 346-47. On the day he was injured, the claimant successfully applied the

lockout-tagout rule, showing that he knew about it. Id. at 348. But he later violated the rule,

resulting in his severe injuries. Id. at 345, 348. We affirmed the Commission’s decision,

-4- deferring to its finding that the claimant’s conduct was “willful.” Id. at 360.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Artis v. Ottenberg's Bakers, Inc.
608 S.E.2d 512 (Court of Appeals of Virginia, 2005)
Brockway v. Easter
456 S.E.2d 159 (Court of Appeals of Virginia, 1995)
Peanut City Iron & Metal Co. v. Jenkins
150 S.E.2d 120 (Supreme Court of Virginia, 1966)
Mills v. Virginia Electric and Power Company
90 S.E.2d 124 (Supreme Court of Virginia, 1955)
Spruill v. C. W. Wright Construction Co.
381 S.E.2d 359 (Court of Appeals of Virginia, 1989)
Riverside & Dan River Cotton Mills, Inc. v. Thaxton
172 S.E. 261 (Supreme Court of Virginia, 1934)

Cite This Page — Counsel Stack

Bluebook (online)
Isidro Avalos Vanegas v. Triple S. Pallets, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/isidro-avalos-vanegas-v-triple-s-pallets-llc-vactapp-2024.